G.R. No. 238298 - Latogan vs. People

On November 8–9, 2009, in Baguio City, petitioner Joel F. Latogan allegedly struck Mary Grace Cabbigat on the head with a piece of wood, applied treachery and disregard of sex, inflicting mortal wounds.
An Information for Murder was filed on February 4, 2010; petitioner pleaded not guilty at arraignment.

On June 5, 2015, RTC Branch 5, Baguio City convicted petitioner of Murder based on circumstantial evidence and sentenced him to reclusion perpetua with damages.
Petitioner’s motion for reconsideration was denied for lack of proper notice of hearing; his belated Notice of Appeal was likewise dismissed, rendering the decision final.

Petitioner filed a Rule 65 certiorari petition in the Court of Appeals (CA), which on September 29, 2015 dismissed it for procedural defects: no motion for reconsideration of the RTC’s order, failure to implead the People, lack of service proof, and no OSG copy.
After an Omnibus Motion for Reconsideration (filed beyond the 15-day period), the CA on February 6, 2018 denied it and refused to relax procedural rules.
Petitioner then filed a Rule 45 petition for review on certiorari before the Supreme Court, arguing that his life and liberty (reclusion perpetua) warranted dispensation of technicalities.

Whether the absence of a proper notice of hearing on the RTC motion for reconsideration justified denial and finality of the RTC decision.
Whether the CA correctly dismissed the certiorari petition and denied due course to petitioner’s appeals based on procedural lapses (failure to implead, serve, timely file, etc.).

Whether petitioner’s life and liberty being at stake (reclusion perpetua) constitute compelling circumstances to relax strict procedural requirements.
Whether gross negligence of counsel in procedural matters should be imputed to the client when it results in deprivation of fundamental rights.